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INTERNATIONAL FIDELITY INS. CO. v. U.S.

No. 89-0310C(6).

745 F.Supp. 578 (1990)

INTERNATIONAL FIDELITY INSURANCE COMPANY, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, E.D. Missouri, E.D.

September 26, 1990.

Attorney(s) appearing for the Case

Thomas M. Dee, Husch, Eppenberger, Donohue, Cornfeld & Jenkins, St. Louis, Mo., G. Steven Ruprecht, Husch, Eppenberger, Donohue, Cornfeld & Jenkins, Kansas City, Mo., for plaintiff.

Wesley Wedemeyer, Asst. U.S. Atty., St. Louis, Mo., Kimberly Forseth, Trial Atty., Office of Special Litigation, Tax Div., U.S. Dept. of Justice, Washington, D.C., for defendant.

MEMORANDUM AND ORDER

GUNN, District Judge.

This matter is before the Court on cross motions for summary judgment. The parties have filed a joint stipulation of uncontroverted facts and have agreed to the disposition of the legal issues pursuant to these motions. Therefore, this Court adopts the joint stipulation of uncontroverted facts as its own and incorporates it herein by reference.

Both parties set forth several arguments in support of their...

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